Practice strives to provide tools and resources to support the safe and effective provision of physical therapy services in all settings.
The Budget Reconciliation legislation that passed the House had some practice implications:
Hourly, non-exempt employees would be able to deduct qualifying overtime pay from their tax returns beginning in 2025.
Government subsidized student loans: presently the Government pays the interest on these loans during enrollment and for 6 months post-graduation. Should the legislation pass the Senate without changes, these loans would remain available, but the government would discontinue subsidizing the interest beginning in 2026. The Graduate PLUS loan program would be eliminated.
The legislation is now being considered by the Senate. Any changes will need to be approved by the House prior to the bill being signed into law.
Released in January, this order requires federal agencies to repeal a minimum of 10 regulations for every proposed new regulation. The intent was to reduce the regulatory burden on businesses and individuals and reduce expenditures.
This EO prompted CMS to put out an RFI on ways to deregulate the Medicare program. APTA saw this as an opportunity and responded with a letter recommending elimination of several regulations contributing to therapists’ regulatory burden: replace CMS’ 8” rule with the AMA midpoint rule, eliminate MPPR, streamline new therapist credentialling requirements, expand POC signature exception to direct access patients and care recertifications, eliminate the KX modifier, make MIPS voluntary for PTs, and expand oversight of MA plans. Stay tuned to see if CMS eliminates these regulations!
New! Alternative Payment Model Community
A new community has been added for providers in value-based care and APM models to ask questions and share information. This community is open to all members.
Resources on Psychological Safety in the Workplace are now available on APTA.org in response to PO7-24-14-07, adopted by the 2024 HOD. Psychological Safety in the Workplace.
The APTA Federal Executive Order Resource Center is now available on the APTA Community: Executive Order Resource Center. APTA has created a tracking chart for Executive Orders and corresponding Judicial Issues/Actions that will be updated weekly.
Two new resources addressing physical therapy workforce predictions are available. The first was published in PTJ: Current and Projected Future Supply and Demand for Physical Therapists From 2022 to 2037: A New Approach Using Microsimulation.
The second resource is The APTA Supply and Demand Forecast 2022-2037. Both predict a physical therapy workforce shortage that will outpace the population growth rate by 2037.
Clinicians who manage patients with Dupuytren’s Disease treated non-surgically with a collagenase injection, may be interested in a case report describing the formation of an ipsilateral axillary web 2+ weeks following injection. Collagenase and AWS. The patient presented with decreased shoulder range of motion and was successfully managed with physical therapy and a pressure garment.
Results from the 2024 APTA elections have been announced. Election Results. Service terms begin in January.
Physical therapists’ eligibility to provide telehealth services under Medicare has been extended.
CMS has published multi-lingual telehealth resources for patients in 6 additional languages including: Arabic, Chinese, Creole, Haitian, Korean, Russian, and Vietnamese. These resources are available at CMS Language Resources.
New specifications for correct coding and billing of UE Myoelectric prostheses have been adopted. The information can be reviewed here: UE Myoelectric Prosthesis Coding.
CMS announced modification of some DME codes previously used to bill for rental UE equipment (dynamic orthoses or serial static stretching devices). Consult your DME MAC website for fee schedule information.
The following code descriptors have been modified for 2025:
| Code | Previous description | 2025 Description |
|---|---|---|
| E1800 | Dynamic adjustable elbow ext./flex. device | Dynamic adjustable elbow ext. AND flex. device |
| E1805 | Dynamic adjustable wrist ext./flex. device | Dynamic adjustable wrist ext. AND flex. device |
| E1825 | Dynamic adjustable finger ext./flex. device | Dynamic adjustable finger ext. AND flex. device |
New code descriptors for 2025:
| E1803 | Dynamic adjustable elbow extension only device |
| E1804 | Dynamic adjustable elbow flexion only device |
| E1807 | Dynamic adjustable wrist extension only device |
| E1808 | Dynamic adjustable wrist flexion only device |
| E1826 | Dynamic adjustable finger extension only device |
| E1827 | Dynamic adjustable finger flexion only device |
Medicare does not pay for orthoses or supports primarily made of elastic or other stretchable materials such as neoprene, spandex, elastane, or Lycra. Previous coding policy excepted code L3923 from this policy if an adjustable insert was included and used to custom fit the support for the patient if the code was submitted with a CG modifier. New guidance indicates the CG modifier has been discontinued with upper extremity orthoses. Hand-finger neoprene, elastic or other soft material supports requiring custom fitting of an incorporated metal or thermoplastic support should be coded as L3923 without a CG modifier. The finger modifiers still apply. If the HFO is composed of the fabrics listed above and does not contain a moldable support, it should be coded A4467: “Belt, strap, sleeve, garment, or covering, any type” and is not covered by Medicare.
For more information, see: https://med.noridianmedicare.com/web/jddme/search-result/-/view/2230703/hand-finger-orthoses-l3923-use-of-cg-modifier.
Medicare orthosis suppliers must renew their supplier number every 3 years. One of the requirements for a participating supplier is maintaining $300,000 general liability insurance policy with the supplier enrollment contractor as the certificate holder. The enrollment contractors changed in November of 2022 so renewing suppliers will have to change their liability policies to reflect the new contractor as their insurance certificate holder. A map showing the new contractor locations can be found here: https://www.cgsmedicare.com/jc/pubs/news/2022/11/cope3059.html.
As of January 1, 2025, CMS has changed the required intervention time threshold for caregiver training services. Unlike other procedure codes that allow billing for sessions lasting 8” or more, CPT code 97550 (caregiver face to face training) can only be billed if training lasts a full 30”. Similarly, 97551 (care giver training to facilitate functional performance) can only be billed if treatment time reaches 15”. Intervention for less than the full amount stated in the code will not be payable.
HHS has issued a revised “Frequently Asked Questions” document for the Good Faith Estimate Requirements for cash-based practices. The updated document can be accessed here: Good Faith Estimate FAQ's
New place of service codes were published In January of 2022:
02: Telehealth Provided in location other than patient’s home (revised)
10: Telehealth Provided in the Patient’s Home (New)
Medicare contractors will not begin processing them until April 4, 2022, but some private insurers have already implemented the codes. Check with individual payers when billing for telehealth services. For more information: Telehealth code changes
The department of HHS instituted regulations designed to improve patients’ access to electronic health information in 2021. A new report details the 299 complaints received by HHS since the start of the program and 211 targeted health care providers. Make sure your practice is compliant with the rules by reviewing the: APTA Info Blocking Advisory.
PTA Supervision Requirements Change
CMS adopted APTA’s proposed change to PTA supervision requirements for outpatient physical therapy practices. PTAs will now be under general supervision in all practice settings in the 49 states already allowing general supervision of PTAs in all settings.
PTA Differential
Beginning in 2022, services provided “in whole or part” by PTA’s are reimbursed at 85% of the PFS.
IN part is defined as >10% of the 15” code performed solely by PTA (not PT and PTA together). If the PT and the PTA each perform billable time for the same CPT code, the services can be reported on separate claim lines with the appropriate modifier (CQ for PTA and GP for PT).
Due to the expiration of the PHE on May 11, 2023, PTAs must receive direct supervision in outpatient settings beginning in 2024.
CMS made permanent changes proposed during the PHE permitting PTs to delegate maintenance therapy in part B settings to their supervised PTA.
APTA has collected data to create the State Medicaid Payment Rate Guide. This guide is an important tool for negotiating payment rates and advocating for improved payment rates in your state. The guide is downloadable here: APTA State Medicaid Payment Rate Guide
APTA and the Private Practice Section have partnered to develop resources and tools to help PT’s address the overuse of prior authorization and utilization management barriers to medically necessary care. This new set of resources includes advice reversing payment denials, dealing with prior authorizations, template letters for patients and providers to legislators, insurance commissioners, employers and state Medicaid offices. This “members only” benefit can be accessed here: State Payer Resources
Anthem now requires documentation of start/stop times for all therapy CPT codes. They have also instituted a new rule that combines the 8” CMS rule and the midpoint rule that has led to provider confusion. APTA payment staff has reached out and is working to reverse the changes.
Tricare has presented significant challenges this year including disruptions in care access and provider payment. APTA payment staff has been communicating to both contractors and the Defense Health Agency (DHA) on behalf of members.
Tricare West: Tricare Healthcare Alliance West has agreed to waive referral approval for its Tricare Prime enrollees through June 30, 2025, opening access to specialty care services for its enrollees.
Tricare East: Humana Military changed claims processing contractor from WPS to Palmetto GPA and has claims processing issues during this transition. DHA reports they are working on the issue and claims processing should be back up to previous standards by the end of June 2025.
If you are still having difficulty with access or payment under these programs, please reach out at: [email protected].
As of January 8, 2025, UHC has modified previously announced prior authorization requirements for PT services delivered in private offices and outpatient hospital settings:
Beginning January 13, 2025, only plans of care requesting more than 6 visits or exceeding 8 weeks will be assessed for medical necessity. Initial consultations do not require prior authorization and up to 6 visits of a member's initial plan of care will be covered without conducting a clinical review when the first 6 visits take place within 8 weeks.
See which plans are impacted and which are excluded.
For all prior authorization questions (all plans): UHC has requested that providers send inquiries/voice concerns/seek guidance via one the methods listed below:
Optum Physical Health Contact Info
Ph: 800-873-4575
Chat: https://www.myoptumhealthphysicalhealth.com/
Email: [email protected]
Cred Email: [email protected]
UHC will not be including PTs in its Gold Card Program at this time.
Humana has contracted with Cohere, a UMN, to handle authorization of therapy services including PT, OT and SLP for all commercial and Medicare Advantage plans. In meetings with APTA staff, Cohere representatives provided some information specific upper extremity conditions and orthoses.
Please contact Marsha at [email protected] to report coverage denials for UE rehab or orthoses.
Eleven states now allow PTs to order imaging. APTA has created resources to guide state chapters considering pursuing imaging ordering for Physical Therapists. Advocacy for Ordering Imaging.